Steele v. Fulton County, 1:15-cv-01351

On Dec. 3, 2013 Officer Russel Popham allegedly obtained false witness identifications and sought identification from Plaintiff’s mother, leading to an arrest warrant.
Plaintiff Eddie Steele was indicted Apr. 23, 2014 on robbery and firearm charges; his suppression motion was denied and a jury convicted him; he was sentenced to 108 months and appealed.
While his criminal case was pending, Steele (pro se) filed a § 1983 suit (Apr. 23, 2015) seeking $2.5 million, alleging Fourth Amendment and due process violations based on perjured witness statements and a tainted warrant.
Magistrate Judge Larkins recommended dismissal under 28 U.S.C. § 1915A(b)(1) for failure to state a claim and for Heck-bar (plaintiff’s success would invalidate the conviction).
The district court conducted de novo review after Steele filed vague objections, dismissed claims against Fulton County and the East Point Police Department for lack of Monell allegations, and dismissed claims against Officer Popham as Heck-barred.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether municipal defendants (Fulton County / East Point PD) are liable under § 1983	County/PD supported Officer Popham’s corrupt actions causing constitutional injury	Plaintiff failed to plead any municipal policy or custom causing the harm	Dismissed: no Monell policy/custom alleged
Whether Officer Popham’s conduct supports § 1983 relief for coerced/false IDs and wrongful warrant	Popham coerced witnesses, pressured mother, used false IDs to obtain warrant — seeks damages	Relief would necessarily imply invalidity of conviction because claims challenge identifications underlying conviction	Dismissed under Heck: claim barred until conviction invalidated
Whether the complaint should survive § 1915A screening (frivolous/fails to state claim)	Complaint alleges constitutional deprivations warranting damages	Claims are conclusory, fail Monell pleading, and are Heck-barred; pro se status considered but pleading still deficient	Dismissed under 28 U.S.C. § 1915A(b)(1) for failure to state a claim
Whether appointment of counsel should be granted	Plaintiff requested counsel	Magistrate denied after finding claims insufficient to proceed	Motion to appoint counsel denied (implicit in dismissal)

Heck v. Humphrey, 512 U.S. 477 (1994) (a § 1983 claim that would necessarily imply the invalidity of a conviction is barred unless the conviction has been invalidated)
Monell v. Department of Social Services, 436 U.S. 658 (1978) (municipal liability under § 1983 requires an official policy or custom)
Wilkinson v. Dotson, 544 U.S. 74 (2005) (Heck bar applies regardless of whether the relief sought is equitable or monetary if success would invalidate confinement)
Cooper v. Dillon, 403 F.3d 1208 (11th Cir. 2005) (defines municipal "policy" and "custom" standards for Monell claims)
Miller v. Donald, 541 F.3d 1091 (11th Cir. 2008) (defines frivolous claim standard under § 1915 screening)